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Section 1557: Deadlines Approach, But Long-Term Prognosis Unclear Under Executive Orders

Section 1557 of the Affordable Care Act mandates nondiscrimination in health care programs managed or funded by the Department of Health and Human Services (HHS), with upcoming deadlines for compliance set for May and July...more

HHS Proposes Significant Updates to HIPAA Security Rule

On January 6, 2025, the U.S. Department of Health and Human Services (“HHS”) Office for Civil Rights (“OCR”) published a Notice of Proposed Rulemaking (“NPRM”) to amend the Health Insurance Portability and Accountability Act...more

Practical Pointers for Compliance With New MHPAEA Regulations

The Departments of the Treasury, Labor, and Health and Human Services have published final regulations under the Mental Health Parity and Addiction Equity Act that prohibit group health plans and health insurers from imposing...more

Courts Invalidate ACA Regulations Following Demise of Chevron Deference

Following the U.S. Supreme Court’s recent decision to overturn its landmark 1984 Chevron decision, three district courts have struck down provisions in nondiscrimination regulations under the Affordable Care Act that prohibit...more

2024 HIPAA Developments

Over the course of the past few months, the Office of Civil Rights (OCR) and the Office of the National Coordinator for Health Information Technology (ONC), both of which are divisions of the U.S. Department of Health and...more

Final Section 1557 Rules: Highlights for Health Plan Sponsors

The U.S. Department of Health and Human Services (HHS) has issued final regulations on the nondiscrimination rules set forth in Section 1557 of the Affordable Care Act. The new rules apply to certain group health plans, as...more

HIPAA Breach Notifications – A Question of Timing

You are the HIPAA privacy official of a hospital or health plan (a covered entity under HIPAA). You receive an email from a vendor that handles protected health information (a business associate), informing you that one month...more

HHS Announces Temporary Copay Accumulator Non-Enforcement Policy

The United States Department of Health and Human Services (HHS) has filed court pleadings stating that it does not intend to initiate enforcement actions against plans that maintain copay accumulator programs....more

Prescription for Chaos: Copay Accumulator Programs Called Into Question

Summary - Employers taking advantage of copay accumulator programs now face unexpected administrative complications following a recent federal court decision....more

Details Upon Details: Compliance Under MHPAEA’s New Proposed Regulations

Summary - The Departments of Labor, Health and Human Services, and the Treasury have proposed regulations under the Mental Health Parity Act that build on prior guidance to set forth requirements for an extremely detailed...more

New Mental Health Parity Guidance Issued

Summary - On July 25, 2023, the Departments of Labor, Treasury, and Health & Human Services (the Departments) released joint proposed regulations and other guidance under the Paul Wellstone and Pete Domenici Mental Health...more

Gag-Clause Attestations Due by End of Year

Summary - By December 31, 2023, health plans and insurers must submit an attestation of compliance with the anti-gag rules of the Consolidated Appropriations Act, 2021 (CAA). The rules apply to all agreements entered into...more

Comprehending the Non-Comprehensive: Proposed Rules Tackle Non-Traditional Coverage

The Departments of Labor, Health and Human Services, and the Treasury have published a set of proposed rules that impose new limits on two types of benefits: short-term limited-duration insurance (STLDI) and fixed indemnity...more

Meet Me at the Corner of No Surprises and …

Summary - The Departments of Labor, Health and Human Services, and the Treasury have issued guidance that coordinates application of the No Surprise Billing rules under the Consolidated Appropriations Act, 2021, with the...more

FAQs Provide Guidance on Preventive Care

Summary - The Departments of Labor, the Treasury, and Health and Human Services have jointly issued FAQs that address the requirement to cover the full cost of certain preventive care services in view of the recent ruling...more

Court Invalidates Certain Preventive Care Requirements

Summary - Health plans and insurance policies may no longer be required to cover the full cost of preventive care that carries an A or B rating by the U.S. Preventive Services Task Force (USPSTF), following a recent ruling...more

Unmuzzled: Time to Attest That No Gags Apply

Summary - The Departments of Labor, Health and Human Services, and the Treasury have issued guidance on how health plans and insurers may attest to their compliance with the anti-gag rules of the Consolidated...more

Holiday Relief for Reporting Requirements

In a new set of Frequently Asked Questions, the U.S. Departments of Labor, Health and Human Services, and the Treasury provide significant relief to health plan sponsors and insurers seeking to report on expenditures for...more

Back and Forth to the Future: HHS Issues Proposed Rules on Nondiscrimination

Summary - The Department of Health and Human Services (HHS) has issued proposed regulations under the nondiscrimination provisions of Section 1557 of the Affordable Care Act (ACA). The proposed rules restore and augment a...more

Technical Guidance Issued on Transparency in Coverage Regulations

On April 19, 2022, the U.S. Departments of Health and Humans Services, Labor, and Treasury (collectively, the Departments) issued guidance which sets forth two separate safe harbors for group health plans and health insurance...more

The CAA Prescription Drug Benefit Reporting Requirement

Summary - The Consolidated Appropriations Act, 2021 (CAA) requires group health plans and health insurers to submit information regarding the costs of prescription drug costs and other health care services each year to the...more

The CAA's New Rules for Health Care Provider Directories

Summary - The Consolidated Appropriations Act (CAA) requires each group health plan and health insurer with a network of providers to maintain a database on a public website that lists the name, address, specialty,...more

The CAA's New Identification Card Requirements

Summary - To help individuals better understand the costs they will bear for medical care, the Consolidated Appropriations Act (CAA) requires health plan ID cards to include clear information about deductibles and...more

Understanding the New Health Care Transparency Requirements

Summary - New rules require group health plans and insurers to disclose pricing information in three phases. This is the third briefing in Ballard Spahr’s series on the Consolidated Appropriations Act, 2021 (CAA) and...more

U.S. Department of Health and Human Services Approves Updates to the List of Preventive Items and Services to be Covered Without...

Revisions to preventive care and screening guidelines will require health plans and health insurance policies to provide 100 percent coverage for additional services for women, adolescents, children, and infants, following an...more

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